Newlook Upholstery Anti Corruption Policy

At Newlook Upholstery, we are committed to conducting business with integrity, transparency, and fairness.

We have a zero-tolerance approach to bribery and corruption and expect all employees, contractors, suppliers, and business partners to uphold the same high standards.

This policy outlines the procedures and expectations relating to anti-bribery and corruption to ensure compliance with applicable laws and to protect the reputation of our company.

1. Kickbacks and Facilitation Payments

  • Facilitation payments, which are small payments intended to secure or speed up routine processes, are considered a form of bribery. Newlook Upholstery strictly prohibits the offer, acceptance, or making of facilitation payments under any circumstances.
  • Kickbacks, which involve giving or receiving something of value in exchange for a business advantage, are not tolerated. No employee or representative may request, offer, or accept a kickback of any kind.

2. Gifts and Hospitality

We recognise that in certain situations, modest gifts and hospitality may form part of legitimate business relationships. However, all gifts and hospitality must be appropriate, transparent, and comply with the following rules:
  • The gesture must be reasonable and in line with the situation, e.g., a box of chocolates at Christmas or a small token of appreciation for completing a significant project.
  • It must not be given or received with the expectation of a return favour.
  • It must not be intended to influence a decision or gain a business advantage.
  • Gifts must be given in the company name, not in the name of an individual employee.
  • Cash or cash equivalents (e.g., gift cards) are strictly prohibited.
  • The value of any gift or hospitality must not exceed £100.
  • It must comply with all relevant local laws and regulations.
  • The gesture must not be given or received in secret.
  • All gifts and hospitality must be reported to the Compliance Manager for review.
Note: In certain cultural situations, it may be inappropriate to refuse a gift outright. In such cases, the gift should be accepted on behalf of Newlook Upholstery and reported immediately.

3. Responsibilities of Employees and Representatives

  • Read, understand, and comply with this policy and any related training provided.
  • Ensure that all business dealings are transparent, ethical, and free from corruption.
  • Report any concerns or suspected breaches of this policy without delay.
Breaches of this policy are treated as gross misconduct and may result in:
  • Disciplinary action up to and including dismissal.
  • Termination of contractual relationships with suppliers, contractors, or other third parties.

4. Raising a Concern

If you suspect bribery or corruption in connection with Newlook Upholstery:
  • Report it as soon as possible to the Managing Director, Paul Ingram, or the Compliance Manager.
  • You may raise concerns about:
    • Being offered a bribe.
    • Being asked to make a bribe.
    • Suspecting another individual of engaging in corrupt activity.
    • Any situation that feels unethical or suspicious.
We encourage an open and honest culture where concerns can be raised without fear of reprisal.

5. Political and Charitable Contributions

  • Newlook Upholstery does not support political parties or make improper donations to gain business advantage.
  • We encourage charitable giving and fundraising for causes aligned with our company values, provided:
    • All donations are transparent and publicly disclosed.
    • Charitable contributions are never used to disguise bribery or corruption.

6. Safeguarding and Protection

We will ensure that no one suffers adverse treatment for:
  • Refusing to pay or accept a bribe.
  • Reporting suspected bribery or corruption in good faith.
Adverse treatment includes dismissal, disciplinary action, demotion, or any detrimental treatment connected to raising a concern.

7. Communication

This policy is communicated to:
  • All employees at the start of employment.
  • Contractors, suppliers, and third parties at the outset of a working relationship.
By working with Newlook Upholstery, all parties agree to comply with the standards outlined in this policy.

8. Record Keeping

Newlook Upholstery maintains accurate and transparent records to support our zero-tolerance stance on bribery and corruption:
  • All financial transactions are properly documented with clear supporting evidence.
  • Records of all gifts, hospitality, and charitable contributions are maintained and reviewed regularly by management.
  • Internal controls and procedures are in place to ensure accountability and traceability.

9. Ongoing Review and Improvement

  • The Compliance Manager regularly monitors and reviews this policy to ensure it remains effective and relevant.
  • Updates may be made at any time to reflect changes in legislation, business practices, or risk factors.
  • Internal controls and anti-bribery procedures are audited periodically to identify areas for improvement.

10. Commitment to Ethical Business

Newlook Upholstery is committed to:
  • Maintaining the highest standards of ethical business conduct.
  • Preventing bribery and corruption at every level of our operations.
  • Building trust and transparency with our customers, employees, and partners.
By following this policy, we protect both our company and those we work with, ensuring that every action we take upholds our reputation for integrity and quality.
Effective Date: This policy is effective immediately and applies to all employees, contractors, and third parties engaged by Newlook Upholstery. Contact: If you have any questions or require clarification on this policy, please contact the Compliance Manager or the Managing Director, Paul Ingram.
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